Investor

Through our untiring effort to maximize customer satisfaction by delivering products of high quality, the group has gained a special position and preference in domestic and international market. As a result the company has been profit making, growing and also dividend paying since its inception in 1986.

Considering the financial year performance and strength of the Company CRISIL (one of the reputed rating agencies of India) has assigned long term rating
"CRISIL A/ STABLE" (pronounced as CRISIL A ) and short-term rating "CRISIL A1" (pronounced as CRISIL A one) to the company. The outlook on the long term rating is Stable.

CODE OF CONDUCT

INTRODUCTION :

GOODLUCK Group is one of India's leading and fastest growing business groups with over 4000 employees and having multi location plants and units. With experience of more than two decades in the industry GOODLUCK has diversified business interests in the national and international market. By recognizing the contribution of the company in the export from the country the Government of India has recognized it as an export house.

The Company’s philosophy on Corporate Governance is built on a rich legacy of fair, transparent and effective governance. This includes respect for human values, individual dignity and adherence to honest, ethical and professional conduct. This enables customers and all stake holders to be partners in the Company’s growth and prosperity.

OBJECT :

This code of conduct document has been created in furtherance of the Company’s commitment to building a strong culture of corporate governance by promoting the importance of ethical conduct and transparency in the conduct of its operations.

The Company’s Code of Conduct not only ensures compliance with the Company Law, the provisions of the listing agreement with Stock Exchanges and other laws, but goes beyond to ensure exemplary Corporate Governance.

APPLICABILITY :

This Code is applicable to the following:
a. All Employees of the Company including Senior Management; and

b. All Directors of the Company.

This Code does not address every possible form of unacceptable conduct and it is expected that the Directors and the Employee shall apply their sound judgment to comply with the principles set forth in the Code.

DEFINITION :

The definitions of some of the key terms used in this Code are given below
"Director" means any Executive, Non-Executive, Nominee or Alternate Director of the Company.

"Employee" means any employee or officer of the Company.

"Relative" means 'relative, as defined in the Companies Act, 2013.

"Senior Management" means personnel of the Company who are members of its Core Management team excluding the Board of Directors and shall include all personnel above the level of Vice-President and all function heads.

KEY REQUIREMENTS :

The members of the Board and senior management personnel are required to operate within their designated authority, prioritizing the company's best interests. They are expected to adhere to the following guidelines:

• Execute their responsibilities with diligence and uphold a high standard of integrity.
• Act with the utmost good faith in all their actions.
• Refrain from participating in decisions concerning matters where a conflict of interest exists or is likely to arise, based on their judgment.
• Disclose and avoid any personal or financial stakes in business transactions involving the company.
• Abstain from engaging in interactions with contractors or suppliers that could compromise the company's ability to conduct business professionally, fairly, and competitively, or that could influence company decisions.
• Avoid holding positions, jobs, or engaging in external business ventures that could harm the company's interests.
• Seek permission from the competent authority and disclose any personal gain-seeking endeavors that arise from the use of corporate property, information, or position before pursuing them.
• Refrain from making statements that could negatively criticize government policies or company actions, potentially straining relations between the company and the public, as well as the company's management and employees, including stakeholders.
• Prevent involvement in any criminal activities that involve moral wrongdoing or go against public policy and result in a conviction.

STANDARD OF CONDUCTS

The Directors and employees shall conduct the Company's business in an efficient and transparent manner in meeting its obligations towards the shareholders and other stakeholders. The Directors and employees shall not be involved in any activity that would have any adverse effect on the objectives of the Company or against national interest. The following elucidates the Company’s position on the manner of conduct of the Company’s business and transactions :

A. CORPORATE CITIZENSHIP & REGULATORY COMPLIANCE

The company shall be committed to good corporate citizenship, not only in the compliance of all relevant laws and regulations but also by actively assisting in the improvement of quality of life of the people in the communities in which it operates.

The company shall not treat these activities as optional, but should strive to incorporate them as an integral part of its business plan.

Employees of the company, in their business conduct, shall comply with all applicable laws and regulations, in letter and spirit, in all the territories in which they operate.

B. EQUAL OPPORTUNITIES

The company shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, religion, color, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin or disability.

Human resource policies shall promote diversity and equality in the workplace, as well as compliance with all local labour laws, encouraging the adoption of best practices.

C. HEALTH SAFETY & ENVIRONMENT

The policy of the company is offering to its employees a safe and healthy workplace. The company is against all forms of exploitation of children and believes in abiding by the laws and applicable regulations for prevention of child labour.

The Company is committed to prevent the wasteful use of natural resources and minimize any hazardous impact of the development, use and disposal of any of the intermediaries or direct materials used in its product and service offerings on the ecological environment.

D. CONFLICT OF INTEREST

An employee or director of the company shall always act in the interest of the company, and ensure that any business or personal association which he / she may have does not involve a conflict of interest with the operations of the company and his / her role therein.

In case of an Employee, where such conflict appears at any time or is in existence at the time of the implementation of this policy, such Employee shall forthwith make a disclosure in writing to the Management. Upon reviewed the Employee may be directed to avoid/resolve the conflict or to take such remedial action as is deemed suitable by management.

A Director shall disclose any potential conflicts of interests to the Board of Directors or any Committee thereof and abstain from participating in the decision making or in influencing the decision on the areas resulting in the potential conflict of interest in accordance with the applicable rules under the Companies Act. In addition, the Director shall provide on a periodic basis, such disclosure as is required by the Board of Directors or any Committee thereof.

If the management becomes aware of an instance of conflict of interest the management shall take a serious view of the matter and consider suitable disciplinary action against the employee.

E. CONFIDENTIALITY

Any information concerning the Company’s business, its customers, suppliers, etc. to which the Directors or the employees have access or which is possessed by the Directors and the employees, must be considered privileged and confidential and should be held in confidence at all times, and should not be disclosed to any person, unless

1. authorized by the Board; or
2. the same is part of the public domain at the time of disclosure; or
3. is required to be disclosed in accordance with applicable laws.

F. EXCLUSIVITY

Senior Officers are expected to devote their full attention with integrity and honesty to the business interests of the Company. They are prohibited from engaging in any activity that interferes with his proper discharge of responsibilities of the Company, or is in conflict with or prejudicial to the interests of the Company.

G. INSIDER TRADING

A Director or the Employees and their relatives shall not derive any benefit or assist others to derive any benefit from the access to and possession of information about the Company, which is not in the public domain and thus constitutes insider information. They shall also ensure compliance with the SEBI (Prohibition of Insider Trading) Regulations, 2015 as also other regulations as may become applicable to them from time to time.

The Company also prohibits its Directors and Employees in undertaking any fraudulent or unfair trade practice in connection with the securities of the Company.

H. PROTECTION OF COMPANIES ASSETS

The Directors and the Employees shall not use the Company’s tangible assets such as equipment and machinery, systems, facilities, materials etc. or intangible assets such as proprietary information, relationships with customers and suppliers, etc. for their personal benefit or for the benefit of a related party or for any purpose other than of conducting the business of the company.

I. PUBLIC REPRESENTATION

The company honours the information requirements of the public and its stakeholders. In all its public appearances, with respect to disclosing company and business information to public constituencies such as the media, the financial community, employees, shareholders, agents, franchisees, dealers, distributors and importers, the company shall be represented only by specifically authorized directors and employees. It shall be the sole responsibility of these authorized representatives to disclose information about the company.

J. GIFT & DONATIONS

The Company, it’s Directors and Employees shall neither receive nor offer or make directly /indirectly any illegal payments, gifts, donations or any benefits which are intended to obtain business or unethical favours. However, the Directors or Employees may receive such nominal gifts which are customary in nature or are associated with festivals.

K. ANTI CORRUPTION & BRIBERY

The employee shall not directly or indirectly offer, promise or receipt of any gift, hospitality, loan, fee reward or other advantage, except bonafide corporate hospitality to improve company’s image, to induce or reward behavior, which is dishonest, illegal or a breach of trust, duty, good faith or impartiality in the performance of a person’s functions or activities (including but not limited to, a person’s public functions, activities in their employment or otherwise in connection with a business) to obtain business advantage(s).

NON- ADHERENCE

The matters covered in this Code are of the utmost importance to the Company, its stockholders and its business partners, and are essential to the Company's ability to conduct its business in accordance with its stated values. We expect all of our Directors and Employees to adhere to these rules in carrying out their duties for the Company.

The Company will take appropriate action against Director or the Employee whose actions are found to violate these policies or any other policy of the Company. In case of breach of this Code, the same shall be considered by the Board of Directors for initiating appropriate action, as deemed necessary.

AMENDMENTS & WAIVER

The Code may be amended or modified by the Board as and when it is found necessary to do so. Any waiver of any provision of this Code for a Director or the Employee must be approved by the Company's Board of Directors.

INVESTOR’S GRIEVANCES

For any query/grievance the investors may contact with :

NODAL OFFICER UNDER IEPF RULES

Name of Nodal Officer : Mr. Abhishek Agrawal
Email ID : investor@goodluckindia.com